The URL can be used to link to this page

Home My WebLink About05-5292 BRIAN D. TENNANT, PLAINTIFF V. JULIANNE TENNANT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - S:2q,?- Ot-UL, : DIVORCE ACTION NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at (717) 240-6195, Carlisle Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 .i BRIAN D. TENNANT, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. OS -S?Z9 JULIANNE TENNANT, : DIVORCE ACTION DEFENDANT COMPLAINT COUNT I - DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Brian D. Tennant, is an adult individual who currently resides at 1400 Bent Creek Boulevard, Apartment 229, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, Julianne Tennant, is an adult individual who currently resides at 2164 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiffs Social Security Number is 082-48-9562. 4. The Defendant's Social Security Number is 055-54-3610. 5. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 6. The Plaintiff and Defendant were married on March 6, 1986, in Northport, Long Island, New York. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in Counseling. 10. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Brian D. Tennant, urges this Honorable Court to enter a Decree of Divorce. COUNT II EQUITABLE DISTRIBUTION 11. Plaintiff incorporates herein by reference Paragraphs 1 through 10 above. 12. Plaintiff and Defendant possess various items of both real and personal marital property, which is subject to equitable distribution by this Court. WHEREFORE, Plaintiff, Brian D. Tennant, requests this Court to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. Respectfully submitted, NEA -ON GOV R & E 'If James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, Brian D. Tennant, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. i c-) 3 0- 5-Brian D. Tennant Dated: BRIAN D. TENNANT, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-5292 Civil Term JULIANNE TENNANT, : DIVORCE ACTION DEFENDANT AFFIDVAIT OF SERVICE I, James G. Nealon, III, Esquire, verify that on the 15th day of October, 2005, 1 served the Defendant with a true and correct copy of the Divorce Complaint by one of the following methods: (CHECK ONE) (X) Service was made by United States Postal Service, first class mail, postage prepaid, certified, restricted delivery, return receipt requested to the Defendant, on the 15th day of October 15, 2005. The return receipt signed by the Defendant is attached hereto. above made ( ) The Defendant was personally served pleading by hand-delivering the same to the at following location and time: at copy of the service was - day of I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subje to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorit Date: with a true and correct Defendant. Personal on the JAMES G. NEALON, III, ESQUIRE A 0 Agent B. 61ved by (Printed Nerve) I C. Date of Dcivery D. Is delivery address different from Item 1? 0 Yes If YES, enter delivery address below. 0 No ? -7 3. Servlce F 1 l?? Ortified Mail ??1 Exprest; Mail O Registered „vtrm Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (EMra Fee) es 2. Article Number (i)ansrer from service label) 7004 2890 0000 6575 4065 Ps Form 3811, February 2004 Domestic Return Receipt toxsss-oz.rn-tsao ¦ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print lour name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: ?lcrq Cankrtq bnRe BRIAN D. TENNANT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5292 JULIANNE TENNANT, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 7, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: lianne Tennant, Defendant C`1 y,_ '- ,? r"`' ?? c.? -i?F _ ? ?y ?? i ? i r f.' _J l i ++..j , __._? p_ .?J ?,j i '\ ;f 1 BRIAN D. TENNANT, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5292 Civil Term JULIANNE TENNANT, : DIVORCE ACTION DEFENDANT AFFIDAVITI OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on October 7, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of both the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE: OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER F43301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. ? •r I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: _ Brian D. Tennant k C w?. BRIAN D. TENNANT, Plaintiff V. JULIANNE TENNANT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-5292 CIVIL ACTION -LAW IN DIVORCE NOTICE TO THE PLAINTIFF If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action have been separated since May 28, 2005, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: d D % b- ?e- J ' anne Tennant, Defendant n 1 -? 5 Fri r,a vs AUG-09-2007 11:46 AM ORIGINAL P, 2 BRIAN D. TENNANT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5292 JULIANNE TENNANT, CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO WITHDRAW CLASMB TO THE PROTHONOTARY: Please withdraw the claim for equitable distribution in the above-captioned divorce action. Date: (;2?1 ?40 By: Brian Tennant, P aintiff 2007-08-09 1t47 Page 2 c„ ??, ?:?, ?,.,>`? ? _-?; ; ? ?.?. ? -,... ? t ?,. -y -? . .. L?l rt`?, .?. ?° ?, ; AUG-09-2007 11;47 AM P. 3 ORIGINAL BRIAN D. TENNANT, plaintiff v. JULIANNE TENNANT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5292 CIVIL ACTION - LAW IN DIVORCE OF NOTICa OF 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 54904, relating to unswoxn falsification to authorities. Date: 81 _?? lcr, By: Brian D. Tennant, ainti 2007-08-0911:48 Page 3 ? ? s? _ ? ?7 ?' - r? , . ,? ; --= ?-- --3 --, _s =- ? =;=i V.j E> < "< r BRIAN D. TENNANT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5292 JULIANNE TENNANT, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section( x) 3301(c) ( ) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: by certified, restricted mail on October 15, 2005, as evidenced by the Affidavit of Service on record. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: by Plaintiff: November 8, 2006; by Defendant: September 1, 2006. (b) (1) Date of execution of the Defendant's Affidavit required by Section 3301(d) of the Divorce Code: June 26, 2007. + w (2) Date of service of the Defendant's Affidavit upon the Plaintiff: Upon counsel for the Plaintiff, James G. Nealon, III, Esquire, by letter dated July 3, 2007. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: 6. Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff. November 8, 2006 and August 10, 2007; by Defendant: September 1, 2006. and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce Decree: by Plaintiff: December 6, 2006 and August 21, 2007; by Defendant: September 7, 2006. Date: 0? 31 , rl JAMES, SMITH, DIETTERICK & CONNELLY, LLP Jo J. o lly, ., Esquire Atte for lldgndant Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 f's"1 rte'] . ,w TN.) t t i r., IN THE COURT OF COMMON PLEAS BRIAN D TENNANT OFCUMBERLAND COUNTY STATE OF PENNA. NO. 05-5292 Plaintiff VERSUS JULIANNE TENNANT Defendant DECREE IN DIVORCE AND NOW, A .r v LOB ! , IT IS ORDERED AND DECREED THAT Brian D. Tennant , PLAINTIFF, AND Julianne Tennant DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COU TA RY ell Q• -6